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      William Cross Antiques

       Personal Information Protection Policy 

      At William Cross, we are committed to providing our clients and or customers’ with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our clients protecting their personal information is one of our highest priorities.

      While we have always respected our client’s and or customers’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA) & Ontario's Personal Information Protection Act  

      We will inform our clients and or customers’ of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

      This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ and or customers’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and or customers’ personal information and allowing our clients’ and or customers’ to request access to, and correction of, their personal information.

      Scope of this Policy 

      This Personal Information Protection Policy applies to William Cross Antiques and William Cross

      This policy also applies to any service providers collecting, using or disclosing personal information on behalf of William Cross or William Cross Antiques


      Personal Information –means information about an identifiable individual such as social insurance number, marital status, religion, income, credit history, medical information, education, and employment information Personal information does not include contact information (described below).

      Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.

      Privacy Officer – means the individual designated responsibility for ensuring that William Cross Antiques complies with this policy and PIPA.

      Policy 1 – Collecting Personal Information

      1.1  Unless the purposes for collecting personal information are obvious and the clients’ and or customers’ voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

      1.2  We will only collect clients’ and or customers’ information that is necessary to fulfill the following purposes:

      ·       To verify identity;

      ·       To verify creditworthiness;

      ·       To identify [client, customer, member] preferences;

      ·       To open and manage an account;

      ·       To deliver requested products and services

      ·       To enrol the client in a program;

      ·       To ensure a high standard of service to our [clients, customers, members];

       Policy 2 – Consent

      2.1 We will obtain clients’ and or customers’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

      2.2 Consent can be provided either orally, in writing, or electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the clients’ and or customers’ voluntarily provides personal information for that purpose.

      2.3  Consent may also be implied where a clients’ and or customers’ is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the clients’ and or customers’ does not opt-out.

      2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients’ and or customers’ can withhold or withdraw their consent for William Cross Antiques to use their personal information in certain ways.  A clients’ and or customers’ decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the clients’ and or customers’ in making the decision.

      2.5  We may collect, use or disclose personal information without the clients’ and or customers’ knowledge or consent in the following limited circumstances:

      ·       When the collection, use or disclosure of personal information is permitted or required by law;

      ·       In an emergency that threatens an individual's life, health, or personal security;

      ·       When the personal information is available from a public source (e.g., a telephone directory);

      ·       When we require legal advice from a lawyer;

      ·       For the purposes of collecting a debt;

      ·       To protect ourselves from fraud;

      ·       To investigate an anticipated breach of an agreement or a contravention of law

      Policy 3 – Using and Disclosing Personal Information

      3.1  We will only use or disclose clients’ and or customers’ personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

      ·       To conduct client, customer, member surveys in order to enhance the provision of our services;

      ·       To contact our [clients, customers, members] directly about products and services that may be of interest;]

      3.2 We will not use or disclose clients’ and or customers’ personal information for any additional purpose unless we obtain consent to do so.

      3.3 We will not sell clients’ and or customers’ lists or personal information to other parties [unless we have consent to do so].

      Policy 4 – Retaining Personal Information

      4.1  If we use clients’ and or customers’ personal information to make a decision that directly affects the clients’ and or customers’, we will retain that personal information for at least one year so that the clients’ and or customers’ has a reasonable opportunity to request access to it.

      4.2  Subject to policy 4.1, we will retain clients’ and or customers’ personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

       Policy 5 – Ensuring Accuracy of Personal Information

      5.1  We will make reasonable efforts to ensure that clients’ and or customers’ personal information is accurate and complete where it may be used to make a decision about the clients’ and or customers’ or disclosed to another organization.

      5.2  Clients’ and or customers’ may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

      Policy 6 – Securing Personal Information

      6.1  We are committed to ensuring the security of clients’ and or customers’ personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

      6.2  The following security measures will be followed to ensure that clients’ and or customers’ personal information is appropriately protected:

      6.3  We will use appropriate security measures when destroying clients’ and or customers’ personal information such as shredding documents, deleting electronically stored information

      6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

      Policy 7 – Providing clients’ and or customers’ Access to Personal Information

       7.1  Clients’ and or customers’ have a right to access their personal information, subject to limited exceptions.

      7.2 Upon request, we will also tell clients’ and or customers’ how we use their personal information and to whom it has been disclosed if applicable.

      7.3 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

      7.4 A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the clients’ and or customers’ of the cost and request further direction from the clients’ and or customers’ on whether or not we should proceed with the request.

      7.7 If a request is refused in full or in part, we will notify the clients’ and or customers’ in writing, providing the reasons for refusal and the recourse available to the clients’ and or customers’.

      7.8 Maximum combines all data-sharing options to reach the highest amount of customers. It uses Conversions API, which shares data directly from Shopify’s servers to Facebook. This means the data can’t be blocked by ad blockers.

      Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

      8.1 The Privacy Officer or designated individual is responsible for ensuring William Cross Antiques compliance with this policy and the Personal Information Protection Act.

      8.2 clients’ and or customers’ should direct any complaints, concerns or questions regarding William Cross organization’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the clients’ and or customers’ may also write to the Information and Privacy Commissioner of British Columbia.

      Contact information for William Cross Antiques, Privacy Officer or William Cross:

                William Cross